PPM Technologies Privacy Policy

Overview

This Privacy Policy is meant to help you understand how PPM Technologies Holdings LLC collects, uses, and protects the personal information we collect. For the purposes of this policy, personal information includes any information that can be used on its own or with other information to identify, contact, or locate an individual, or to identify an individual in context.

We may collect and use your data in various circumstances, including when: (1) you provide information to us directly; (2) you access and browse our websites or any mobile applications we offer; (3) we need to fulfill an obligation we have to you; (4) it is necessary for our business interests in providing and offering the services available on our websites or mobile apps; and (5) where we are required to do so by law.

We may need certain personal information, including your contact and payment information, for you to purchase goods or services from us, or to respond to inquiries. If you do not wish for us to collect this information, you will not be able to take advantage of our services.

1. What Personal Information Do We Collect, and When Do We Collect It?

When you use our websites or our services, we may collect certain personal information from you, including:

Contacting PPM Technologies. When you use the ‘Contact Us’ form on our webpage to submit comments or questions we may require that you submit your name, email, and any other information you choose to provide via your message.

Product Orders. When you order products from us, or through us from one of our partners, we will require you to provide us with certain information, which includes your name, title, address, email address, and credit card information.

Automated Information.  When you access our website we automatically receive and record information from your browser. The information can include your IP address or unique device identifier, cookies, and data about which pages you visit. This information helps us operate and provide the services available on our website. It is collected automatically and stored in log files. We may combine this information from your browser or your mobile device with other information that we or our partners collect about you, including across devices. This information is used to prevent fraud, to keep our website and the services secure, and to analyze and understand how you and other visitors use our website.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information. We use the following cookies:

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is different, so look at your browser’s Help menu to learn how to modify your cookies.

If you disable cookies, some features that make your site experience more efficient and some of our services will not function properly.

Third Parties. We may engage third parties to provide certain services. These service providers may collect or otherwise process personal information on our behalf. We currently work with Multiview, Inc., who provides us with marketing services. Multiview collects the following data on our behalf, but may not ever provide us with the data: IP address; interactions with PPM web pages or advertisements; browsing and/or search history; and professional and employment related data. Multiview’s Privacy Policy can be found here: https://www.multiview.com/privacy-policy.

Under the California Consumer Privacy Act (“CCPA”), the various information we collect may fall into the following defined categories: identifiers, commercial information, internet or network information, professional or employment information, and inferences.

2. How Do We Use Your Information?

When we collect and use your personal information, we may do so for the following purposes:

Providing and Improving Our Website, Services, and Products.  We may collect and use your personal information to improve our website and services, or tailor the content on our websites. Such use is necessary for our legitimate interest in improving our website and services and in understanding how they are used. Furthermore, we may ask for your consent or provide an opt-in to post certain personal information on our websites (e.g., for testimonials). This may include sharing personal information with business partners to analyze statistics, trends, behaviors, and other information to improve our websites and services.

When you place orders on our website, we will need to collect certain information from you to provide you with the services or products you order.

Emails From Third-Parties. We may use and share personal information to send users offers and information from third-parties offering products and services in a similar space. This may come in the form of a contest, giveaway, or product advertisement. In such examples, we may request your consent or provide you with an opt-in for such use and sharing.

Keeping Our Services Operational, Safe, and Secure.  We may use your personal information to debug our website, and for safety and security purposes, including sharing your information for such purposes. We do so because it is necessary to pursue our legitimate interests in ensuring the security of our website and users, including you.

Legal and Safety.  We may retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law; prevent imminent physical harm or financial loss; or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of our terms of use. In these cases, our use of your data may be necessary for our legitimate interests in keeping our website secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage, and complying with a legal obligation, a court order, or exercising or defending legal claims. It could also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share data to prevent loss of life or personal injury). In case we are asked to disclose any of your personal information out of public interest, vital interest, or because of a legal action, we will disclose no more than necessary to achieve the applicable interest.

Service Providers.  We may engage certain third-party companies and individuals (including payment processors and advertising and marketing partners) as necessary to operate our website and to provide the products and services available on it. Our engagement of service providers may be necessary for us to provide the products and services available on our website.

Change of Business. In the event of a merger, acquisition, sale, bankruptcy, or other form of a change of control, the personal information we collect on you may be subject to transfer to a third-party entity. You acknowledge that if such a transfer were to occur, PPM Technologies, or its acquirer or successor, may continue to use your personal information as set forth in this Privacy Policy.

Liabilities. We may use and share personal information to protect PPM Technologies, our users, or others to take precautions and protect against liability, third-party claims, allegations, investigations, abusive and unlawful uses, and other forms of liability.

Employees, Contractors, Authorized Parties. PPM Technologies may use and share personal information with employees, agents, contractors, affiliates, subsidiaries, and other third-parties if we believe there is reason to do so with regard to our products and services. PPM Technologies will aim to choose third parties who align with this Privacy Policy.

Disclosure for Business Purposes. In the last 12 months, we have disclosed the following categories of CCPA personal information for our business purposes: identifiers and commercial information. Our business purposes for disclosure include auditing PPM’s website to understand how consumers use the website; detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; performing services on behalf of PPM’s business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business; and debugging to identify and repair errors in the website.

“Sale” of Personal Information. We have not sold any personal information over the past 12 months, as the term “sold” is defined under the CCPA.

3. When Do We Transfer Your Data?

We may, in the course of storing your information, transfer the data to or through foreign countries depending on where our relevant serves or service providers are located. Please be aware that the privacy laws and standards in certain countries may differ from those in your country of residence.

4. How Long Do We Keep Your Data?

We will retain your data only as long as necessary for the uses stated in this policy, including to the extent reasonably necessary to comply with our legal obligations (for example, to comply with applicable tax or revenue laws), resolve disputes, enforce agreements, and as otherwise described in this policy.

We may also retain log files for analytics purposes. These are generally only kept for a short time, unless required for safety, to make improvements, or to comply with requirements as stated above.

You may email us at egapu@ppmtech.com to request that we remove your personal information. However, if you request that we remove personal information we will need to keep that data long enough to fulfill any contractual obligations we have, including any contractual obligations we have to you. It is important to note that appropriate measures will be taken to remove personal information if you request that we do so, however, after a request to remove such personal information, there may be recoverable information on our servers or elsewhere in some form, and we cannot not remove personal information that must remain as required under applicable laws.

5. EU and UK Users

If you are in the EU or the UK, CMC’s legal basis for collecting and using any personal information described in this Privacy Policy depends on the nature of the personal information in question and the specific context in which we collect it. For the purpose of this Section 5, “personal information” has the meaning given in the GDPR, which may include the personal information and site usage information discussed above, but does not include information exempted from the scope of the GDPR.

We may process personal information according to the following legal bases:

• We need to perform under a contract with you or to take steps at your request prior to entering into a contract;
• You have given us your consent to do so;
• The processing is necessary in order to protect your vital interests or those of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest;
• The processing is in our legitimate interests and it is not overridden by your rights; and
• To comply with the law.

If you are a resident of the EU or UK, you may have certain rights related to your personal information:

• Right to be informed: you can request to know what personal information an organization is processing and why (we provide this information to you in this Privacy Policy);
• Right of access: you can request a copy of your information;
• Right of rectification: if the data held is inaccurate, you have the right to have it corrected;
• Right to erasure: you have the right to have your information deleted in certain circumstances;
• Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the information retained;
• Right to portability: you can request a copy of certain information in a machine-readable form that can be transferred to another provider;
• Right to object: in certain circumstances (including where information is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing; and
• Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you would like to inquire into or exercise any of these rights, please email us at egapu@ppmtech.com, contact us via the contact form on ppmtech.com, or call us at 800.246.2034. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

6. California Users

If you are a California user, you may have certain rights related to your personal information:

• You can request the following information about how we have collected, used, disclosed, and “sold” your personal information during the past 12 months:
  • The categories of personal information we have collected and used;
  • The categories of sources from which we collected personal information;
  • The business or commercial purpose for collecting and/or selling personal information.;
  • The categories of third parties with whom we share personal information;
  • Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third party recipient; and
  • Whether we’ve sold your personal information, and if so, the categories of personal information received by each category of third party recipient;
• You can request a copy of the personal information we have collected about you during the past 12 months;
• You can ask us to delete the personal information we have collected from you;
• You can ask that we do not sell your personal information.  If you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes;
• If we know you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your personal information before we do so;
• You are entitled to exercise the rights described above free from discrimination. This means we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

If you are a California user, you may exercise your California privacy rights described above as follows:

• To request to exercise your information, access or deletion rights, please email us at egapu@ppmtech.com, contact us via the contact form on ppmtech.com, or call us at 800.246.2034. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your CCPA rights. Following California law, we take reasonable precautions to verify the identities of those California residents submitting requests to delete or access personal information, or to learn more about how their personal information is processed. We cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity, understand the nature of the request, and respond to it.
• We do not currently “sell” personal information (as “sell” is defined under the CCPA). We may, like many companies, use services that help deliver interest-based ads to you and may transfer personal information to business partners for their use. Making personal information (such as online identifiers, browsing activity, or listed interests) available to these companies may be considered a “sale” under the CCPA. You can request to opt out of such “sale” of your personal information at this link, by emailing us at egapu@ppmtech.com, contacting us via the contact form on ppmtech.com, or calling us at 800.246.2034.

Please note that you will still see some advertising, regardless of your selection. We may require verification before processing California residents’ requests to exercise their rights under the CCPA.

You may empower an authorized agent to submit CCPA requests on your behalf. We may require verification before proceeding any request submitted through an authorized agent.

California residents we know to be younger than 16 years of age will by default be treated as though they have exercised a request to opt out of the sale of their Personal Information with respect to information provided directly to us (as opposed to information automatically collected from them through technical means). We do not permit such users to opt-in to the sale of their Personal Information, unless they provide proof that they are no longer under the age of 16.

7. Changes to this Privacy Policy

We may update the terms of this Privacy Policy in our sole discretion, including as necessary to comply with additional regulations or to meet new business demands. We will post notice on our website if we update this Privacy Policy.

8. Third-Party Links

Occasionally, at our discretion, we may include links to third-party websites from our website. These third-party websites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites.

9. Children Online Privacy Protection Act

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (“COPPA”) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not market to children under 13, and we do not intentionally collect the personal information of children under 13 years old. All users of our website must be: (a) at least 18 years of age; or (b) between 13 and 18 years of age with the direct supervision of someone at least 18 years of age. You may not use our website or the services available through them if you are under the age of 13. If you are the supervisor of a user who is between the ages of 13 and 18, you are responsible for their actions while using our website or the services provided through them.

10. Data Security

PPM Technologies cannot and does not ensure or warrant the security of any or all personal information you transmit to PPM Technologies, and you do so at your own risk. PPM Technologies makes commercially reasonable efforts to ensure the security of our systems.

The Fair Information Practices Principles form the backbone of privacy law in the United States, and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In accordance with the Fair Information Practice Principles we endeavor to notify the users via email within 7 business days should a data breach occur, unless other applicable requires earlier notice.

11. CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. If at any time you would like to unsubscribe from receiving future emails from us, follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.

Contact Us

If there are any questions regarding this Privacy Policy, you may contact us using the information below.

PPM Technologies Holdings LLC
Address:  500 E. Illinois St., Newberg, OR 97132
Contact: Elayna Apuya
Phone: 800.246.2034
Fax: 503-538-3141
Email:  egapu@ppmtech.com